Due to a prior engagement, I cannot attend the Selectboard Meeting this Wednesday, June 27th. I am submitting this letter -- a slightly condensed version of my recent four-part post on the Norwich listserv -- as public comment to the Town Manager’s presentation on the Emergency Communications Tower proposed for the hill above the Town Garage on New Boston Road.Based on my attendance at last Wednesday’s public forum, the presentation demonstrates his strengths in abundance:
- Digesting extremely complex data into clear, informative overviews;
- Providing comprehensive, thorough treatment of an issue that doesn’t gloss over difficult issues;
- Strong efforts to minimize infrastructure cost through siting and grant coordination;
- An open demeanor and patience with divergent viewpoints;
- Apparently very good rapport with Fire, Police, and Public Works heads to assess and address their needs.
Indeed, I paraphrase (may not be verbatim because I don’t know shorthand) a statement he made at the most recent Public Forum which illustrates his focus and priorities regarding the proposed tower quite well:
“I have been focused on finding a solution that meets the needs of our three public safety departments. I think if it meets the needs of those three departments it meets the needs of our 3,400 residents.”
While I ultimately disagree with the statement, I respect the viewpoint behind it and honestly believe we are fortunate to have a town manager in place today who brings such dedication, intelligence, and consciousness of role to the position.
I disagree with the statement’s “what’s good for GM is good for America” conclusion because it defines the problem as a purely administrative/public safety issue.
In fact, a 198’ tower impacts home values and views, individual property rights traditionally governed by land use regulation. It also requires expanding the town’s bonding authority to pay for the tower, raising political considerations in addition to purely fiscal concerns.
Finally, it is a case study in how administrative bureaucracy inevitably operates on different criteria -- and responsive to a different constituency -- than elected officials, even in very small towns.
My comments:
This is not the first standalone communications tower proposed for Norwich.
I was Chair of our Development Review Board early last decade when Verizon Wireless applied to build a cell tower above Upper Loveland Road. At the time, cell towers were popping up all along I-91 and I-89 as Verizon sought to create a corridor of uninterrupted cell coverage along both interstates.
To their credit, Verizon knew they would face Development Review Board review in Norwich and they worked hard to anticipate likely points of friction with neighboring landowners.
As required by our zoning regulations, their initial proposal limited the height of their tower to the minimum they felt acceptable to achieve their coverage goals. To further minimize adverse visual impact on neighbors, they sited the tower where few -- if any -- houses could see it even when leaves are down. They also designed the tower as a mock white pine so it would be lost in the surrounding tree cover to those who might view it from afar. They did all this precisely because they knew they had to undergo a permitting process.
The resulting tower -- similar to the tower on the hilltop just southeast of Exit 12 on I-91 -- is difficult to see even when you’re looking for it. It achieves Verizon’s coverage goals with minimal impact on neighbors or those traveling on public roads in their viewshed.
In my opinion, the Verizon cell tower is a positive example of permitting and land use regulation. DRB review under clear, considered regulatory criteria helps smart developers tailor their proposals to anticipate objections, mitigating those they feel they cannot fully satisfy. It gives those most impacted by the proposed development an opportunity to challenge the most offensive impacts under objective standards. A transparent process has the advantage of being recognized to be fair even if some parties don't get everything they want. This leads to a better development plan overall and a politically more acceptable outcome in the end.
In terms of impacts, I see no difference between this tower proposal and Verizon's cell tower built seven years ago. However, the proposed towers themselves could hardly be more different:
Where Verizon achieved their coverage objectives by siting a 82’ tower on a heavily forested height, the current proposal’s only concession to neighbors was the choice to keep it under 200’ so it won’t require a flashing red light on top.
Where Verizon selected their proposed site to balance coverage objectives against the tower’s visual impact upon neighboring properties -- and chose colors and camouflaging to further minimize visual impacts -- the current proposal (admittedly in an effort to contain costs) appears to have limited in-depth site analysis to town-owned properties. They then limited coverage objectives to what would be possible from the public works/transfer station site with a tower just under 200’.
Finally, where Verizon understood and anticipated the regulatory requirements, there appears to be some confusion among town officials whether a DRB hearing is even needed for this proposed tower.*
It appears to me this confusion regarding the need for DRB review has allowed the tower proposal to get ahead of itself, leading to a proposed design that may be penny-wise, but pound foolish; a proposal that might have met less opposition and produced a better result for all had the applicable DRB review criteria been in mind from the start.
-----
* From my reading of our zoning regulations, there is simply no question the proposed tower requires DRB review:
Section 1.02(A) clearly states our regulations apply to “all lands in this community” without exception for town-owned land.
Section 1.03(A) states, “No land development shall commence within the jurisdiction of the Town of Norwich except in compliance with the provisions of these regulations.”
Section 4.11 provides expedited DRB review of “Public Facilities” but explicitly requires those facilities conform to our zoning regulations with respect to “location, size [and] height.”
The extensive location, size and height criteria for “telecommunications facilities” such as the proposed tower are set out in Section 4.13 - - the same regulations we applied to the Verizon tower eight years ago.
Our Town Manager and the three department heads of our emergency services departments -- fire, police, and public works -- make a very persuasive case for the need to address our emergency communications infrastructure. At last week’s public forum, they each recounted specific incidents where their people or town residents were in significant danger in areas where existing emergency communications cannot reach today.
One Chapel Hill Road resident echoed these concerns, referring to an incident where emergency medical response was dangerously delayed due to limited emergency communications coverage.
Due to difficult topography and the radio “shadows” cast by the ridges fanning out from downtown, our existing emergency communications coverage cannot reliably reach many houses along the valleys throughout town, most notably Beaver Meadow/Bragg Hill/West Norwich and the Goodrich Four Corners/Route 132 area in northeast Norwich.
FCC-mandated “narrow-banding" -- first announced several years ago -- takes effect at year-end, throttling down existing bandwidth for emergency services and, if not addressed, resulting in significantly worse coverage than exists today.
Based on the coverage maps provided at the public forum, a proposed 198’ tower above the Town Garage -- together with complementary coverage from towers in neighboring towns -- would substantially improve emergency services communications above existing coverage levels even after the narrow-banding rules come into effect at year-end.
However, due to tower site and height characteristics, two areas would remain in the shadows without some or any emergency services communications coverage.
The biggest shadow falls over old West Norwich comprised of Chapel Hill Road, Mitchell Brook Road, Tigertown Road, Podunk Road, and some parts of outer Beaver Meadow Road including adjacent sections of Tucker Hill and Bragg Hill Roads.
A smaller shadow appears over Ladeau and Kerwin Hill Roads near Thetford.
Given the need to borrow money through bonds to build this tower anyway, doesn’t it make sense to thoroughly research the possibility of finding a single site -- whether publicly- or privately-owned -- that might extend coverage to these two remaining shadows?
As it now stands, our coverage objective is actually whatever we can achieve from a site that is currently town-owned with a tower that is just short enough to avoid a flashing red light on top. Cold comfort to those in its shadows.
In other words, given its public safety purpose, shouldn’t our coverage objective for this tower be to eliminate all existing shadows and cover 100% of the public within our borders if at all possible?
Can we find a single tower site that might eliminate the West Norwich and Kerwin Hill shadows entirely?
It may be the cost of acquiring and building a tower on a more effective site is too much for town residents to stomach.
It may be a more effective tower site imposes other impacts that make it unsuitable.
It may be there simply is no single site that can achieve a 100% coverage goal.
We can only find out by trying.
The point is, Verizon did a thorough analysis of coverage and site development characteristics on a number of potential sites before bringing forward a specific proposal. Based on the responses to questions at last week’s public forum, it appears we haven’t.
Verizon understood our regulations limit tower height to 20’ above the surrounding tree line lacking compelling evidence a higher tower is absolutely required to achieve a coverage objective. (See NZR Section 4.13 (C)(b)) As a result, they sought out sites on higher terrain, using topography to achieve better coverage without exceeding the 20’-above-tree-line limitation. In other words, they achieved their coverage objective -- admittedly more modest than ours -- by siting a smaller tower at a higher elevation.
The proposed tower at the Town Garage site does just the opposite, seeking to overcome a valleyside location at 750’ elevation with 198’ of tower structure -- probably 120’-140’ feet above the surrounding tree line. The potential for delay in getting a tower of this size through DRB and Act 250 review could well mean we miss the year-end FCC narrow-banding deadline anyway.
Based on the propagation maps shared at the public forum, it would appear a smaller tower more consistent with our zoning regulations, sited closer to the Sharon border -- along the ridge that runs between Beaver Meadow and Turnpike Roads where elevations reach more than twice the proposed tower site -- might achieve better -- perhaps 100% -- coverage for town residents with minimal impact on neighbors or viewsheds. The cost involved and other practical considerations can only be determined by a more thorough investigation of these options.
I respect the initial impulse to try to limit costs by focusing on town-owned properties. I understand the sense of urgency to erect a tower before the narrow-banding throttle takes effect at year-end. It’s hard to see how we can meet that deadline if we seriously consider higher elevation and privately-owned sites given the additional acquisition and construction requirements involved.
Nevertheless, if we are making a major long-term investment to improve emergency services communications coverage in town, let’s do the up front work now - - while there’s still time -- to see whether we can achieve 100% coverage for our residents and the emergency personnel we depend upon.
It may cost more at the outset and we may miss the year-end deadline as a result, but these near-term concerns pale, in my opinion, set against even a single fatal incident occurring in one of these shadows that might have been avoided had we taken the time now to eliminate the shadows entirely.
